My letter to TC - ATPL injustice

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DeltaHotel
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My letter to TC - ATPL injustice

Post by DeltaHotel »

This is an email I wrote to my Transport Canada Regional Director and a few other administrators. Hope it pays off . but im not holing my breath
Hi,

I am writing to voice my dissatisfaction with the CAR's with regards to the minimum requirements for obtaining the Airline Transport Pilots License (ATPL).

CAR 421.34 states that a pilot shall have a total of 1500 hours including a minimum of:

(a) 250 hours PIC
(b) 100 hours night flying
(c) 100 hours cross-country
(d) 75 hours instruments

The clause that, in my opinion, raises an injustice is the one that requires a pilot to have 250 hours PIC in order to be eligible for the ATPL.

This clause insinuates that a pilot that flew as a 1st officer for years did not acquire enough experience to occupy the Captain's seat in a 12,500lbs aircraft (which requires the ATPL).

For instance, we consider that a pilot who flew on the Twin Otter on wheel, floats, skis, flew a Dash 8 on the Quebec Lower North Shore, Labrador and Newfoundland (known for it's thick fog) and that flew a Jetstream 32 IS LESS qualified than a flight instructor who flew a Cessna 172 in VFR weather or a pilot that towed a banner for 1000 hours.

This requirement is a great handicap to me and I find myself in a situation where obtaining the ATPL must be part of my career making decisions. This at a time where most carriers are handcuffing their pilots with training bonds and contracts.

Some pilots will opt for renting a Cessna to build the PIC time they are missing. This alternative is very expensive, it is out of reach for most pilots and it offers NO additional knowledge or expertise.

There is a flaw with CAR's 421.34 (4) (a) and it is penalizing hundreds of pilots.

I ask for your help to rectify this situation.

Thank you,
I invite you all who are stuck in this situation to send your thoughts to :
andre.lapointe@tc.gc.ca
kristine.burr@tc.gc.ca
yaprak.baltacioglu@tc.gc.ca
guylaine.roy@tc.gc.ca
helena.borges@tc.gc.ca

This is one of many CARs regulation that needs to be revisited. We need to put some pressure.

Thank you
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Cobra64
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Re: My letter to TC - ATPL injustice

Post by Cobra64 »

So you went straight to a First Officer job and are now realized that you are stuck without enough PIC time? Since you are flying in such extreme conditions (thick fog), you are probably making great money. Buy into a 1/4 share on a 172 or something and you will get up to 250 before to long. I doubt your letter will get anything more than an eye roll from anybody at TC.
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Re: My letter to TC - ATPL injustice

Post by Nark »

As a first officer did you make the final decision at any point not to continue a flight?
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double-j
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Re: My letter to TC - ATPL injustice

Post by double-j »

The Captains seat may only be a few feet away, but when you get there its a whole different ball game.

Its truly amazing how perceptions change when the buck stops with you.

Sorry dude, no sympathy here. Go fly a navajo pic and get some command time.

jj
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Re: My letter to TC - ATPL injustice

Post by North Shore »

You might want to re-phrase one of the middle paragraphs, as it's not contributing to your message:
For instance, we consider that a pilot who flew on the Twin Otter on wheel, floats, skis, flew a Dash 8 on the Quebec Lower North Shore, Labrador and Newfoundland (known for it's thick fog) and that flew a Jetstream 32 IS LESS qualified than a flight instructor who flew a Cessna 172 in VFR weather or a pilot that towed a banner for 1000 hours.
Taking out the bit about -8, Quebec and Jetstream, it reads "For instance, we consider that a pilot who flew the Twin Otter ....... IS LESS qualified..etc.." I don't think that's what you mean. (I do realise that English might not be your mother tongue.) If you replace the 'IS LESS' with 'IS MORE', then it means what you want it to.

I think that the crux of the issue comes down to the difference between 'experienced' and 'qualified.' Sure, your Dash/Jetstream etc.. F/O has experienced more, but, when it comes down to it, they aren't the final decision makers - the person sitting on their left is. OTOH, the single pilot is making the calls by themself, and living with those decisions - and that's what the 250 PIC is all about.

Apart from that, those rules (421.34) have served hundreds of people well - suck it up and get the PIC from somewhere - all the rest of us did.

Full marks for trying to change the system, though.
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The Old Fogducker
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Re: My letter to TC - ATPL injustice

Post by The Old Fogducker »

An aircraft of 12,500 lbs does not require an ATPL. One which requires 2 pilots by Type Certificate does.

There is no reference to 12,500 lbs in the licensing requirements anywhere.....not since 1996 when the CARs were introduced.

Further, the ICAO ATPL issue minimums are met by "our" minimums ... so you're barking up the wrong tree at only the scent of a Raccoon ... he's up the ICAO tree ... so go bark there instead.

Save your Shakespearean theatre mock outrage performance for that letter, not one to Transport.

I'm sure over at ICAO HQ, they'll get right on it and change the world-wide standard to rescue you from meeting that horrible requirement to have a massive 250 hours of PIC time.

Those oppressors need to be put in their place man ... go to it.

The Old Fogducker
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Hedley
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Re: My letter to TC - ATPL injustice

Post by Hedley »

It brings a tear to my eye, when I see youthful and idealistic notions, such as that life (and the government) ought to be fair.

Life ain't fair. The government ain't fair. Get used to it. Bad things happen to good people all the time, and the people who do the bad things rarely get punished. Generally they get rewarded.
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Re: My letter to TC - ATPL injustice

Post by Liquid Charlie »

What is being proposed south of 49 is ATP -- 1500 hours and that no one can sit a seat in a 121 carrier unless they have an ATP -- don't know what the break down for hours for ATP will be but regardless it will mean no ATP - no "heavy metal" --
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iflyforpie
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Re: My letter to TC - ATPL injustice

Post by iflyforpie »

Sorry, zero sympathy from me.

The hardest thing about flying is knowing when to say no. Only the PIC has that responsibility and only PIC hours can give you that experience--regardless of the type of aircraft or the conditions flown.

This is unlike when you are training (I would imagine pretty much all of your PIC hours are in the training environment if you don't have 250PIC) where there isn't a ton pressure to do a flight if the weather is bad, or a piece of equipment isn't working, or where you have to decide between fuel and payload.
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Last edited by iflyforpie on Fri May 07, 2010 11:35 am, edited 1 time in total.
Geez did I say that....? Or just think it....?
pika
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Re: My letter to TC - ATPL injustice

Post by pika »

Simply bewildering. Mind boggling even. Photoshop CS4 is your best bet.
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Re: My letter to TC - ATPL injustice

Post by Ollie »

When I first started reading this post, I expected you to be pushing for higher PIC mins!
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Re: My letter to TC - ATPL injustice

Post by oldncold »

try losing 90 k a yr because a poi cannot read the rules properly. so sorry fella. one of the things ya youngs annoys me sometimes (but not always ) is before single engine turbine ifr _(lets leave that dead horse for another day shall we ) it took took 6-10 yrs of flying in the north before one could get on to some turbine twin or big piston -ie dc3 or convair etc.

why? because the routes were regulated and subsidized by taxpayer and there was very little movement. except attriition or retirement.

It has only been since 1985 deregulation that has allowed the growth of smaller companies which in turn higher lower time pilots into this nice turbine equip. many right out of flight school.

yes the biz has changed driven by many factors .I am not that ancient to recogonize that . but the sense of entitlement that many fo/ have expressed ( not all of them of course) but the genernal trend seems of that generation me want it now . and when they don't get it now I have seen better behaved 2yr olds in a grocery store . so back on track tc doesn't follow its own rules on occasion it sets up process and then when it does not suit their adjenda tough bannas . most of the posters here over 35 yrs old have. run into similar issues along their career path. so suck it up get the 250 pic and get the atpl.

Also Many 2crew machines or single crew aircraft where the company ops manual states that ops are 2 crew, all it takes is a letter from your operations mgr or cp, half of your co- jo counts as pic. towards atpl.

if you have managed to get into something twin turbine with less than 1500 hrs be greatful there are a lot of guys here with 4-8 times your time doing the ei golf team not my choice either . :idea: :prayer:
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Re: My letter to TC - ATPL injustice

Post by navajo_jay »

No sympathie here again. PIC time is the most important, and 250 PIC is really low to be considered ATPL.

Being an F/O is easy, that's what i'm doing right now after being captain on less than 12 500lbs aircrafts. I have around 1500 multi-pic and let me tell you that i am more relax now. I don't have the final call. It's really not the same game. I really don't regret my time flying smaller aircraft on the left seat.
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Re: My letter to TC - ATPL injustice

Post by ScudRunner »

Whaaaaaaaaaaaaaaa Whaaaaaaaaaaaaaaaaa Whaaaaaaaaaaaaaaaa

Image



I really hope your trolling ...................
double-j wrote:The Captains seat may only be a few feet away, but when you get there its a whole different ball game.

Its truly amazing how perceptions change when the buck stops with you.

Sorry dude, no sympathy here. Go fly a navajo pic and get some command time.

jj
+1 you can really tell the guys who went up north flew floats and such vs the Right seat meat. A little off topic but with that being said my one gripe with contrails is when an instructor with 500 MPIC is "more qualified" than a pilot who flew otters/ beaver/Caravans and PC-12's for thousands of hours doesn't stand a chance to get an upgrade with out the multi PIC. On the other hand I knew to stay far away from Alberta without that time in the book so I don't have much sympathy for this sort of thing.

Sorry Delta Hotel, I lump your kind in with the guys who went straight to Jazz, you missed the best part of your career and the best education one can get.
This is one of many CARs regulation that needs to be revisited. We need to put some pressure.
I totally agree they minimums should be raised.
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Cobra64
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Re: My letter to TC - ATPL injustice

Post by Cobra64 »

I think I am going to email Transport Canada and get them to give me my MIFR because I have watched the Kings School DVDs and really how hard could it be.
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lionheart27
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Re: My letter to TC - ATPL injustice

Post by lionheart27 »

Getting your PIC time should be your priority before your sitting with 1200-1500 hrs TT. Those are the hours the employer is going to look at more closely. If you notice most employers post min. PIC hours first. An ATPL can be frozen and made when the total time is reached.

That's why the idea of instructing is most popular, as one is learning the skills of command. The shared cross country or shares in an aircraft is another way to go. The actual command skill is what's important here.
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Re: My letter to TC - ATPL injustice

Post by ZBBYLW »

Sorry buddy, but I truly think you don't know what it's like to be the PIC. PIC (whether it be Single pilot in a 'Ho or two crew in a Modern jet) is much different than sitting in the right seat. You may feel that you have been involved in the decision making, and involved you would have been. The only problem is you never had to make the critical decision - it was always your captain.

There is a reason why the Co-Jo time is worth 1/2 TT towards your ATPL.

If anything, I feel that the 250 hours PIC are quite low. I feel they are that low so people like your self, who are F/Os can get close to becoming a captain at some point, rather than being for the greater good.

When I finished flight training - I chased down the PIC time first, before I get into a 704/705 type operation, so I can upgrade one day. Before you got your current job you should have looked at the requirements and chosen the best steps for you.

Ask for a LOA so you can build PIC time so you can come back as a captain. If your company likes you, and wants you to becoming a Captain with them - they will let you go get your time.

Cheers
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Re: My letter to TC - ATPL injustice

Post by ILS26_Steep »

Delta Hotel,

Sorry my friend but like the others I agree with them. Your decision to take the F/O spot with little PIC time was your decision and don't burden TC for your misfortune.

However, one thing I want to point out to you, is that within your letter to Transport Canada. You did not really specify any type of mitigation to the issue your bringing forward to them. Your basically complaining about the rules, but HOW WOULD YOU MITIGATE IT? Give them a basis to consider and back that up. i.e. Remove the 250PIC time. If I were to read your letter, I could easily say.. By christ he's right. LET's raise the requirement to 500PIC time and therefore enhance the qualification level!

I'd be interested in a response that you receive from transport. Good Luck
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Re: My letter to TC - ATPL injustice

Post by Codeweaver »

Ya know, I don't post very often as you all can see, but I have to jump on this one. As a former Chief Pilot, and I will be blunt, your scenario in no one's problem but your own. With the exception of you not being upgradable in your current employment. The PIC requirement is there for a reason. As most everyone who has responded stated, once you get that left seat you are in a different world. You cannot equate sitting in the right seat to decision making in the left no matter what type of flying you have been doing. Justify it all you want, it is just not the same. Suck it up and get some PIC time, it doesn't what kind of time or what type of A/C you do it in, PIC time is PIC time. Period, end of story.

Good luck to you.
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Re: My letter to TC - ATPL injustice

Post by Hedley »

It is pretty funny that the people who lived the Cinderalla story - they got right seat as 200hr wonders - are now bitterly complaining about their good fortune :wink:
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Re: My letter to TC - ATPL injustice

Post by double-j »

Ya know, on second thought I am with you. In fact I have composed my own letter of dissatisfaction at the injustice as well... only my target is Air Canada! here goes.



Hi,

I am writing to voice my dissatisfaction with Air Canada with regards to the minimum requirements for obtaining the position of Airbus Captain.

Air Canada states that a pilot shall have a total of 1500 hours including a minimum of:

(a) ATPL
(b) real world experience
(c) Years of senority


The clause that, in my opinion, raises an injustice is the one that requires a person with no experience is not eligible for the position.

This clause insinuates that a person who watched every episode of "MAYDAY" did not acquire enough experience to occupy the Captain's seat in a Airbus aircraft (which requires the ATPL).

For instance, we consider that a person who watched the aircraft fly through thunderstorms, volcanic ash, the Swiss Air inflight fire (known for it's thick smoke) and that has read Sully's book TWICE! is LESS qualified than a Jazz pilot who flew a Dash8 in VFR weather from YYJ-YVR for 10000 hours.

This requirement is a great handicap to me and I find myself in a situation where obtaining the Airbus captaincy must be part of my career making decisions. This at a time where most carriers are handcuffing their pilots with hourly requirements and experience.

Some pilots will opt for actually gaining experience and advancing through knowledge to get the position they are missing. This alternative is very expensive, it is out of reach for most people and it offers NO additional shortcuts or (whats in it for me?).

There is a flaw with experience and qualifications is penalizing millions of non-pilots.

I ask for your help to rectify this situation.
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Last edited by double-j on Fri May 07, 2010 1:12 pm, edited 1 time in total.
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Re: My letter to TC - ATPL injustice

Post by ZBBYLW »

double-j wrote:Ya know, on second thought I am with you. In fact I have composed my own letter of dissatisfaction at the injustice as well... only my target is Air Canada! here goes.



Hi,

I am writing to voice my dissatisfaction with Air Canada with regards to the minimum requirements for obtaining the position of Airbus Captain.

Air Canada states that a pilot shall have a total of 1500 hours including a minimum of:

(a) ATPL
(b) real world experience
(c) Years of senority


The clause that, in my opinion, raises an injustice is the one that requires a person with no experience is not eligible for the position.

This clause insinuates that a person who watched every episode of "MAYDAY" did not acquire enough experience to occupy the Captain's seat in a Airbus aircraft (which requires the ATPL).

For instance, we consider that a person who watched the aircraft fly through thunderstorms, volcanic ash, the Swiss Air inflight fire (known for it's thick smoke) and that has read Sully's book TWICE! is LESS qualified than a Jazz pilot who flew a Dash8 in VFR weather from YYJ-YVR for 10000 hours.

This requirement is a great handicap to me and I find myself in a situation where obtaining the Airbus captaincy must be part of my career making decisions. This at a time where most carriers are handcuffing their pilots with hourly requirements and experience.

Some pilots will opt for actually gaining experience and advancing through knowledge to get the position they are missing. This alternative is very expensive, it is out of reach for most people and it offers NO additional shortcuts or (whats in it for me?).

There is a flaw with experience and qualifications is penalizing millions of non-pilots.

I ask for your help to rectify this situation.
Very well written! Well done!
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DeltaHotel
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Re: My letter to TC - ATPL injustice

Post by DeltaHotel »

So much for support from your peers eh ! lol

I respect your points of view. But I still think this regulation doesn't make sense.

Cheers
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Re: My letter to TC - ATPL injustice

Post by cdnpilot77 »

DeltaHotel wrote:So much for support from your peers eh ! lol

I respect your points of view. But I still think this regulation doesn't make sense.

Cheers

How did you ever expect support for this from other pilots that paid their dues and EARNED the requirements?
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Tim
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Re: My letter to TC - ATPL injustice

Post by Tim »

the bid for support went well...im sure the folks at the TC office are having about the same reaction.

gotta agree with everyone else. the rules arent new, should have considered them.
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